United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 216: Hockridge memorandum in support of motion for judgment of acquittal (June 19, 2025)
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Defendant's Memorandum in Support of Motion for Judgment of Acquittal, Document 216 in Case No. 4:24-CR-00287-O in the Northern District of Texas, Fort Worth Division, filed 06/19/25 on behalf of Stephanie Hockridge, also known as Stephanie Reis. The memorandum argues that the government failed to prove the single, unified conspiracy charged in Count One of the superseding indictment, that a Fifth Amendment variance caused substantial harm not cured by Vargas-Ocampo, that she did not knowingly join any conspiracy or submit a knowingly false loan application for Body Politix LLC, and that no pattern of materially false applications was shown. It further contends the wire fraud counts fail for want of a unified scheme, knowledge that PPP loan applications were false, or causation of the wires in Counts Two through Five, and that venue was not proved on any count.
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“United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 216: Hockridge memorandum in support of motion for judgment of acquittal (June 19, 2025).”
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Case 4:24-cr-00287-O Document 216 Filed 06/19/25 Page 1 of 41 PageID 2438
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION
UNITED STATES OF AMERICA, §
§
Plaintiff, §
§
v. § Case No. 4:24 CR-00287-O
§
STEPHANIE HOCKRIDGE, a/k/a § (02)
STEPHANIE REIS, §
§
Defendants. §
DEFENDANT’S MEMORANDUM
IN SUPPORT OF MOTION FOR JUDGMENT OF ACQUITTAL
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TABLE OF CONTENTS
Table of Authorities .......................................................................Error! Bookmark not defined.
Summary and Introduction ............................................................................................................. 1
Legal Standard ................................................................................................................................ 3
Discussion ....................................................................................................................................... 4
I. The Government Failed to Prove the Conspiracy Charged in Count One Beyond a
Reasonable Doubt................................................................................................................. 4
A. The Government Failed to Prove the Single, Unified Conspiracy Charged in the
Superseding Indictment .......................................................................................................... 5
B. The Government’s Fifth Amendment Violation Caused Substantial Harm ................. 10
C. Vargas-Ocampo Does Not Remedy the Government’s Fifth Amendment Violation .. 11
D. The Government Failed to Prove Beyond a Reasonable Doubt That Ms. Hockridge
Knowingly Agreed to Join Any Conspiracy ......................................................................... 12
E. The Government Failed to Prove Beyond a Reasonable Doubt That Ms. Hockridge
Submitted a Knowingly False Loan Application for Body Politix LLC .............................. 17
F. The Government Failed to Prove a Pattern of Materially False Loan Applications ..... 19
II. The Government Failed to Prove the Wire Fraud Charges Beyond a Reasonable Doubt . 21
A. The Government Failed to Prove a Unified Scheme to Defraud .................................. 22
B. The Government Failed to Prove that Ms. Hockridge Knew That PPP Loan
Applications Were Materially False ..................................................................................... 23
C. The Government Has Failed to Prove That Ms. Hockridge “Caused” Any of the Wire
Transfers Described in Counts Two Through Five............................................................... 27
III. The Government Has Failed to Prove Venue on Any of the Counts ................................. 28
A. The Government Failed to Prove Venue Is Proper for the Conspiracy Count, Thereby
Entitling Ms. Hockridge to Acquittal on That Count ........................................................... 28
B. The Government Has Likewise Failed to Demonstrate Venue for Any of the Wire
Fraud Counts ......................................................................................................................... 32
Conclusion .................................................................................................................................... 34
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TABLE OF AUTHORITIES
Page(s)
Cases
Brooks v. United States,
164 F.2d 142 (5th Cir. 1947) ...............................................................................................5, 10
Jackson v. United States,
328 U.S. 750 (1946) ...................................................................................................................3
Kotteakos v. United States,
328 U.S. 750 (1946) .........................................................................................................4, 9, 10
Kousisis v. United States,
145 S. Ct. 1382 (2025) .............................................................................................................23
Loughrin v. United States,
573 U.S. 351 (2014) ...........................................................................................................32, 33
Neder v. United States,
527 U.S. 1 (1999) ...............................................................................................................22, 32
United States v. Boyd,
478 F. App’x 826 (5th Cir. 2012) ............................................................................................15
United States v. Camiel,
689 F.2d 31 (3d Cir. 1982).................................................................................................21, 22
United States v. Capistrano,
74 F.4th 756 (5th Cir. 2023) ....................................................................................................11
United States v. Cornet,
195 F.3d 776 (5th Cir. 1999) ...................................................................................................30
United States v. Davis,
666 F.2d 195 (5th Cir. 1982) ...................................................................................................28
United States v. Elliot,
571 F.2d 880 (5th Cir. 1978) .................................................................................................6, 9
United States v. Fahra,
643 F. App’x 480 (6th Cir. 2016) ..........................................................................................5, 6
United States v. Fells,
78 F.3d 168 (5th Cir. 1996) .....................................................................................................27
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United States v. Ganji,
880 F.3d 760 (5th Cir. 2018) .........................................................................1, 4, 12, 14, 15, 17
United States v. Garcia Mendoza,
587 F.3d 682 (5th Cir. 2019) ...................................................................................................28
United States v. Gengler,
No. 1:08-cv-12, 2009 WL 5549225 (E.D. Va. Oct. 23, 2009) ................................................22
United States v. Holloway,
377 F. App’x 383 (5th Cir 2010) .............................................................................................12
United States v. Hoover,
467 F.3d 496 (5th Cir. 2006) .....................................................................................................5
United States v. Jones,
733 F.3d 574 (5th Cir. 2013) .....................................................................................................6
United States v. Miles,
360 F.3d 472 (5th Cir. 2004) ...................................................................................................30
United States v. Morris,
568 F.2d 396 (5th Cir. 1978) ...................................................................................................26
United States v. Nicosia,
360 F. Supp. 814 (N.D. Ind. 1973) ..........................................................................................16
United States v. Owens,
724 F. App’x 289 (5th Cir. 2018) ............................................................................................28
United States v. Perez,
223 F. App’x 336 (5th Cir. 2007) ............................................................................................31
United States v. Rodriguez-Lopez,
756 F.3d 422 (5th Cir. 2014) ...................................................................................................29
United States v. Skillern,
947 F.2d 1268 (5th Cir. 1991) .................................................................................................14
United States v. Starks,
515 F.2d 112 (3d Cir. 1975).......................................................................................................9
United States v. Strain,
396 F.3d 689 (5th Cir. 2005) .......................................................................................28, 29, 32
United States v. Swafford,
512 F.3d 833 (6th Cir. 2008) .................................................................................................5, 6
iii
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United States v. Taglia,
922 F.2d 413 (7th Cir. 1991) ...................................................................................................16
United States v. Thomas,
690 F.3d 358 (5th Cir. 2012) ...................................................................................................28
United States v. Vargas-Ocampo,
747 F.3d 299 (5th Cir. 2014) (en banc) .............................................................................10, 11
United States v. Varkonyi,
611 F.2d 84 (5th Cir. 1980) .......................................................................................................3
United States v. Velencia,
600 F.3d 389 (5th Cir. 2010) ...................................................................................................22
United States v. White,
569 F.2d 263 (5th Cir. 1978) .......................................................................................12, 14, 17
United States v. Wieschenberg,
604 F.2d 326 (5th Cir. 1979) ...................................................................................................31
United States v. Williams,
20 F.3d 125 (5th Cir 1994) ........................................................................................................3
United States v. Winship,
724 F.2d 1116 (5th Cir. 1984) .................................................................................................27
United States v. Xu,
599 F.3d 452 (5th Cir. 2010) .....................................................................................................3
Universal Health Services v. United States ex rel. Escobar,
579 U.S. 176 (2016) ...........................................................................................................22, 23
Constitution, Statutes, and Regulations
U.S. Const. amend. V...............................................................................................2, 4, 5, 9, 10, 21
U.S. Const. amend. VI .......................................................................................................27, 31, 32
18 U.S.C. § 1343 ............................................................................................................................33
Business Loan Program Temporary Changes; Paycheck Protection Program as
Amended by Economic Aid Act, 86 Fed. Reg. 3692, 3694–95, 3708 (Jan. 14,
2021) ........................................................................................................................................24
Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act, Pub.
L. 116-260, §305, 134 Stat. 1182, 1996–97 (Dec. 27, 2020) (codified at 15
U.S.C. § 636m(h)(2)) ...............................................................................................................24
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Rules
Fed. R. Crim. P. 18 ........................................................................................................................28
Fed. R. Crim. P. 18 ........................................................................................................................31
Fed. R. Crim. P. 29 ..........................................................................................................................3
Fed. R. Evid. 801 .....................................................................................................................10, 30
Other Authorities
LaFave, Israel & King, Criminal Procedure § 16.3(f) (2d ed. 1999) ............................................31
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SUMMARY AND INTRODUCTION
Between 2020 and 2021, Blueacorn served more than 700,000 borrowers. See 6/13 Tr.
299:17–299:21. 1 In 2021, VIPPP served nearly 2,000 borrowers. Yet the Government has
introduced just a tiny sliver of the applications submitted through Blueacorn and VIPPP in a vain
effort to prove that Ms. Hockridge conspired to commit PPP fraud. Even that sliver has been found
wanting. The Government introduced no smoking gun: although it introduced communications
indicating that other people may have conspired to commit fraud, the Government’s vast trove of
documents in this case yielded vanishingly little as to Ms. Hockridge. Instead, the Government has
relied on the uncorroborated say-so of Eric Karnezis—a proven, prolific liar—and other witnesses
who ultimately admitted that they had no evidence that Ms. Hockridge ever entered into a
conspiratorial agreement. As the Court’s jury charge instructs, the jury may not “convict upon the
unsupported testimony” of an “alleged accomplice” unless the jury finds such testimony “credible
beyond a reasonable doubt.” Jury Charge at 7. If the jury follows the Court’s instruction, it would
have no choice but to acquit. This Court should not put the jury through the trouble.
The Government has also relied on the insinuations that Ms. Hockridge must have known
about fraudulent applications submitted by her husband and his alleged coconspirators. But Ms.
Hockridge is her own person. United States v. Ganji, 880 F.3d 760, 767–68 (5th Cir. 2018) (“Mere
similarity of conduct among various persons and the fact that they have associated with or are
related to each other is insufficient to prove an agreement.”). The Government has not presented
evidence sufficient to convince a rational jury beyond a reasonable doubt that she is guilty of
anything but unwittingly associating with business partners who turned out to be fraudsters.
Likewise, as the undisputed evidence established, the applicable regulations encouraged Ms.
1
All citations are to the daily rough transcript.
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Hockridge and all other actors participating in the PPP application process to rely on the borrowers
themselves to submit applications that were “true and accurate in all material respects.” 6/13 Tr.
272:15–19 (Zelaya). On such anemic evidence tying Ms. Hockridge to the criminal acts of her
alleged coconspirators, a rational jury could not conclude, beyond a reasonable doubt, that Ms.
Hockridge is guilty of any count of the Superseding Indictment.
But its failure to submit sufficiently persuasive evidence of Ms. Hockridge’s guilt is just
the beginning of the Government’s failings. As Ms. Hockridge extensively argued in her motion
to dismiss, the Superseding Indictment charged Ms. Hockridge with a single, unified conspiracy
and scheme to defraud. Mtn. to Dismiss (Doc. #91); Renewed Mtn. to Dismiss (Doc. #180). Yet
based on the evidence adduced at trial, a rational jury could not conclude that any such unified
conspiracy or scheme existed; instead, the evidence showed that were at least two separate courses
of conduct here, if not many, many more. Those courses of conduct were divided between entirely
different rounds of the PPP—rounds that were five months apart and subject to separate laws and
regulations—and also involved different operations, scales, and participants. As the evidence
further demonstrated, there was no interdependence among the majority of the borrowers whose
loan applications the Government has alleged (without sufficient evidence) to be fraudulent—and
in all but a few cases, not even any contact with Ms. Hockridge. Instead, the Government’s proof
has shown a “hub and spoke” conspiracy without a “rim,” which, as the Supreme Court has held
for more than 70 years, means the Government’s proof, even viewed it the light most favorable to
the prosecution, established a multitude of separate conspiracies, not a single conspiracy. The
Government’s proof therefore represents an impermissible constructive amendment to and
variance from the charges of the Superseding Indictment, in violation of the Fifth Amendment.
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Finally, and fatally, the Government has failed to establish venue. That is because it did
not introduce evidence that any coconspirator performed an act in furtherance of a conspiracy in
the Northern District of Texas. At best, it has located Ms. Hockridge or another alleged
coconspirator in this District while the alleged conspiracy was ongoing. But mere presence,
without proof of an accompanying act in furtherance of the conspiracy, is not enough to establish
venue. Likewise, the Government’s evidence demonstrated that any acts allegedly undergirding
Counts Two through Five took place in Arizona, not in the Northern District of Texas. Ms.
Hockridge therefore respectfully requests that the Court grant her motion for judgment of acquittal
on each count of the Superseding Indictment.
LEGAL STANDARD
Under Rule 29, after the Government closes its evidence, “the [C]ourt on the defendant’s
motion must enter a judgment of acquittal on any offense for which evidence is insufficient to
sustain a conviction.” The fact that there is “some evidence” to suggest the defendant’s guilt is not
enough. See Jackson v. Virginia, 443 U.S. 307, 320 (1979) (holding that the existence of “some
evidence” supporting a charge “is simply inadequate to protect against misapplications of the
constitutional standard of reasonable doubt”); see also id. (finding that it cannot “seriously be
argued” that the mere presence of evidence “that has any tendency to make the existence of an
element of a crime slightly more probable than it would be without the evidence . . . could by itself
rationally support a conviction beyond a reasonable doubt.”).
Instead, in determining the sufficiency of the evidence, the “relevant question is whether,
after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact
could have found the essential elements of a crime beyond a reasonable doubt.” United States v.
Xu, 599 F.3d 452, 453 (5th Cir. 2010) (cleaned up) (emphasis added). For that standard to be
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satisfied, it is not enough that the evidence merely be consistent with a Defendant’s guilt, because
that would not satisfy the reasonable doubt standard. See United States v. Varkonyi, 611 F.2d 84,
85 (5th Cir. 1980). Instead, the question is whether, assuming the jury believes the evidence
submitted by the Government to be true, whether it is so strongly reflective of guilt that it would
leave a rational factfinder “firmly convinced of a defendant’s guilt,” without any “real possibility”
that the defendant was innocent. United States v. Williams, 20 F.3d 125, 128 (5th Cir 1994). In this
case, the Government has fallen short of that mark.
Moreover, a “conviction may not rest on mere suspicion, speculation, or conjecture, or an
overly attenuated piling of inference upon inference,” nor can it “rest on an unwarranted inference,
the determination of which is a matter of law.” United States v. Ganji, 880 F.3d 760, 767 (5th Cir.
2018) (cleaned up). But despite its blundering attempts to convict Ms. Hockridge based upon her
mere association with her husband and his confederates, “inference upon inference” is all that the
Government’s case amounts to at the end of the day.
DISCUSSION
I. The Government Failed to Prove the Conspiracy Charged in Count One Beyond a
Reasonable Doubt
The Superseding Indictment’s Count One alleged a single, unified conspiracy to commit
wire fraud by submitting falsified PPP loan applications or helping others do the same.
Superseding Indictment (Doc. #163) ¶ 14. The Government has failed to prove that charge beyond
a reasonable doubt.
To begin, the Government has not presented evidence of a single, unified conspiracy. At
best, it has proven (at least) two, distinct courses of conduct in 2020 and 2021—divided between
different PPP rounds, which were subject to different laws and regulations, and separated by a
five-month closure of the PPP. At worst, it has proven “hub-and-spoke” courses of conduct with a
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multitude of borrowers and loan processors who were not interdependent. The Government has
therefore committed the precise error that the Supreme Court found fatal in Kotteakos v. United
States, 328 U.S. 750 (1946). In short, the Government’s deviation from the Superseding Indictment
represents an impermissible constructive amendment, or alternatively a fatal variance, in violation
of the Fifth Amendment.
But even if the evidence were capable of establishing a single conspiracy beyond a
reasonable doubt (which it is not), the Government has failed to prove beyond a reasonable doubt
that Ms. Hockridge agreed to join any conspiracy at all. Indeed, the Government’s very first
witness distanced Ms. Hockridge from any conspiracy, and other Government witnesses confirmed
that she took steps to undermine any conspiratorial aims—not to join them. Thus, even if the
Government’s witnesses were believed, no rational jury could conclude beyond a reasonable
doubt that she joined in their conspiracy.
A. The Government Failed to Prove the Single, Unified Conspiracy Charged in the
Superseding Indictment
“The Fifth Amendment provides for criminal prosecution only on the basis of a grand jury
indictment.” United States v. Hoover, 467 F.3d 496, 500 (5th Cir. 2006) (cleaned up). Thus, once
a grand jury returns an indictment, only the grand jury may amend it. Id. The Government violates
the Fifth Amendment by seeking a conviction on a “materially different theory or set of facts than
that with which [the defendant] was charged” in the indictment. Id. (cleaned up); see also id. at
502 (“Therefore, we conclude that because the indictment charged Hoover with making one false
statement, and the jury instructions allowed the jury to convict him for making a different false
statement, the trial court constructively amended Hoover’s indictment.”).
In particular, the Government may not obtain an indictment that charges a single, unified
conspiracy and then seek a conviction by proving multiple conspiracies. Brooks v. United States,
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164 F.2d 142, 143 (5th Cir. 1947) (“[W]hile it would have been entirely permissible to have tried
all these persons and all these conspiracies together in one indictment in several counts . . . it was
reversible error to send them all to the jury under an indictment in one count charging one
conspiracy.”): see also id. (“[D]ue process as to each defendant required for a conviction that the
evidence be strong enough to exclude every other reasonable hypothesis than the guilt of that
defendant on the precise conspiracy charged.” (emphasis added)); United States v. Swafford, 512
F.3d 833, 842 (6th Cir. 2008) (holding that, because the Government “failed to prove” the single
charged conspiracy and, “there [was] a variance between the crime charged (a single conspiracy)
and the crime proved (multiple conspiracies)”); United States v. Fahra, 643 F. App’x 480, 490
(6th Cir. 2016) (“Specifically, when the indictment alleges a single conspiracy but the evidence at
trial shows multiple conspiracies, the variance between the indictment and proof, if it is prejudicial,
is reversible error.”).
Multiple factors determine whether a course of conduct represents one, or rather multiple,
conspiracies. Courses of conduct represent separate conspiracies if they occur at separate times, as
well as if the “manner and means” of the conspiracies differ. Fahra, 643 F. App’x at 492–93. So
too when the supposed conspirators do not share a single goal or are “not truly interdependent[,]
or where the various activities sought to be tied together cannot reasonably be said to constitute a
unified scheme.” United States v. Elliot, 571 F.2d 880, 901 (5th Cir. 1978); Swafford, 512 F.3d at
842 (“The government failed to prove that the methamphetamine cooks were acting in furtherance
of a common goal or that there was any significant interdependence among them.”); see generally
United States v. Jones, 733 F.3d 574, 580–81 (5th Cir. 2013) (identifying factors for identifying
multiple conspiracies for purposes of double jeopardy).
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Here, all of those factors point to the same conclusion Ms. Hockridge urged in her earlier
motion to dismiss Count One of the Indictment (Doc. #91): at best, the Government has presented
evidence of two or more separate courses of conduct—not a single, unified conspiracy—which
represents a fatal constructive amendment, or alternatively a fatal variance, from the Superseding
Indictment’s single-conspiracy charge. As detailed below, the two courses of conduct occurred in
distinct times; involved different operations and scales; and involved different participants. The
evidence simply would not allow a rational factfinder to find a single conspiracy as charged in
Count One beyond a reasonable doubt.
1. The Evidence Shows at Least Two Courses of Conduct at Two Different Times
As the Government’s SBA witness Ms. Zelaya testified, the Paycheck Protection Program
had two distinct rounds: PPP Round 1 began on April 3, 2020 and ended on August 8, 2020. 6/16
Tr. 248:16–249:9; see also 6/12 Tr. 52:24–53:3 (Flores testifying that PPP funding ran out in
August 2020). For five months thereafter, the SBA accepted no PPP applications whatsoever. 6/16
Tr. 249:7–249:24 (Zelaya). PPP Round 2 did not begin until January 2021, after Congress passed
a new law and new funds began to flow to borrowers. See 6/12 Tr. 64:13–64:22 (Flores testifying
that Congress passed another PPP round in approximately December 2020, and funding began
flowing in the middle of January 2021).
This second PPP round was not just a repeat of the first: Under the first set of PPP laws
and regulations, banks had lent primarily to their existing clients, leaving small businesses
(especially sole proprietors and independent contractors) out in the cold. See 6/12 Tr. 139:3–
139:16 (Flores). During the second round of PPP, however, the rules made it easier for applicants
to apply for PPP loans and also incentivized lenders to originate more PPP loans by paying a higher
fee, including a significantly higher fee for smaller loans. 6/12 Tr. 65:2–65:12 (Flores).
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These two, distinct PPP rounds necessarily divide this matter into at least two, distinct
courses of conduct. As of August 8, 2020, PPP funding had dried up, and it was uncertain whether
Congress would authorize additional funding. See 6/16 Tr. 249:7–249:24 (Zelaya). As of that date,
therefore, any course of course of conduct related to obtaining PPP loans necessarily ended.
Matters lay dormant for five months thereafter, until Congress finally authorized new PPP funding,
which began to flow in January 2021. The second course of conduct overlapped with this second
PPP Round.
2. The Two Courses of Conduct Differed in Scale, Manner, and Means
Time was not all that divided these separate courses of conduct. The business itself differed
fundamentally in 2020 and in 2021. In 2020, because the first PPP round favored banks’ existing
clients, the universe of potential borrowers was necessarily smaller, and so loan processors like
Blueacorn had fewer opportunities to help prospective borrowers obtain loans. Hence, Blueacorn’s
operations were limited during that initial round: participants merely obtained loans for themselves
and their direct contacts. E.g., 6/12 Tr. 52:2–52:16 (Mr. Flores testifying that in 2020 he submitted
a false loan application with the help of Michael Cota and Nathan Reis). The second course of
conduct, however, coincided with greater borrowing opportunities for small businesses and sole
proprietors—thus expanding the opportunities for loan processors like Blueacorn to help. As a
result, operations expanded dramatically in 2021, with Blueacorn growing to approximately 25 to
40 people. (6/12 Tr. 99:20–99:24) (Flores).
3. The Two Courses of Conduct Had Different Participants
In addition to timing, scale, manner, and means, the two courses of conduct also involved
different participants. Most notably, Ms. Hockridge played a limited role in the 2020 conduct—so
much so, that Government witness Mr. Hochberg testified that Ms. Hockridge was involved in the
conspiracy in 2020, 6/16 Tr. 313:9–11. Conversely, Government witness Eric Karnezis was not
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involved in the 2020 course of conduct. 6/12 Tr. 283:24–284:1 (Mr. Flores testifying that Mr.
Karnezis was not part of the same conspiracy). And Blueacorn itself was different, too: During the
second course of conduct, the Blueacorn tradename applied to a new entity, Fin Cap, which took
on a new role as a lender service provider. (6/12 Tr. 64:7–64:12; EX26).
In sum, a rational factfinder could not conclude, beyond a reasonable doubt, that the
Government has proven a single, unified conspiracy. The evidence shows at least two distinct
courses of conduct, which occurred during different PPP rounds, entailed different scales and types
of operations, and involved different constituents.
4. The Government Has Failed to Demonstrate Any Interdependence Among the
Borrowers, as Would Be Required to Make Them Part of a Single Conspiracy
Proving two distinct courses of conduct is the best-case scenario for the Government. But
in fact, the Government has proven as many distinct courses of conduct as there were borrowers
who worked with Blueacorn and VIPPP. The Government proves multiple, distinct courses of
conduct when it proves that a central person deals with a host of other individuals who do not
know about one another and who are not interdependent. Kotteakos, 328 U.S. at 754–55 (“[T]he
pattern was ‘that of separate spokes meeting a common center,’ though we may add without the
rim of the wheel to enclose the spokes. The proof therefore admittedly made out a case, not of a
single conspiracy, but of several . . . .”); Elliot, 571 F.2d at 901 (holding that in a “chain conspiracy,”
the “scheme which is the object of the conspiracy must depend on the successful operation in each
link of the chain”). Such is the case here. Several of the individuals who submitted, or helped
submit, fraudulent PPP loans through Blueacorn and VIPPP were not even aware of each other.
The Government’s first witness Mr. Flores testified that he was unaware that Eric Karnezis was a
member of any conspiracy. 6/12 Tr. 283:24–284:1. Nor did the successful operation of Blueacorn
or VIPPP depend on the “successful operation of each link of the chain.” Elliott, 571 F.2d at 901.
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The Government has not shown that one borrower’s loan application affected another’s—or that
one loan processor’s work affected another’s. In short, a rational factfinder could not conclude,
beyond a reasonable doubt, that the Government has proven a single, unified conspiracy.
B. The Government’s Fifth Amendment Violation Caused Substantial Harm
The proof’s deviation from the Superseding Indictment has caused, and will cause,
substantial prejudice to Ms. Hockridge. Most glaringly, the deviation poses a problem for the jury’s
verdict. The Superseding Indictment requires the jury to vote on a single conspiracy count. But the
Government has proven at least two, distinct courses of conduct—and in fact, many, many more—
not a single, unified conspiracy. A general verdict against Ms. Hockridge on the single conspiracy
count will not reveal whether the jury concluded unanimously that she was part of one course of
conduct versus another. See United States v. Starks, 515 F.2d 112, 116 (3d Cir. 1975).
Another source of prejudice is Ms. Hockridge’s indisputably limited involvement in the
2020 course of conduct, see, e.g., 6/12 Tr. 128:22–129:2, 156:21–157:4, 175:25–176:13; 6/16 Tr.
313:9–11. Because her role was so limited—and because the Government consistently failed to
prove that she knew about any fraudulent loans in 2020, a rational jury could not conclude, beyond
a reasonable doubt, that she agreed to join any conspiracy in 2020.
The Government has tried this case, however, as if Ms. Hockridge was a member of all
conspiracies, spanning 2020 and 2021. The Government has introduced ample evidence—such as
through Mr. Flores—of conduct from 2020, primarily attributable to Mr. Flores, Mr. Hochberg,
and Ms. Hockridge’s husband . That evidence includes hearsay introduced under the exception for
coconspirator statements—even though Ms. Hockridge was not a member of the relevant
conspiracy. See, e.g., 6/12 Tr. 317:2–323:10 (admitting July 2020 email between Oliver O’Connell
and Nathan Reis, including partially for the truth of the matter asserted, under the Rule 801
exception for coconspirator statements). This introduction of evidence about an alleged conspiracy
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that did not involve Ms. Hockridge risks “transference of guilt from one to another across the line
separating conspiracies, subconsciously or otherwise”—a danger “so great that no one really can
say prejudice to substantial right has not taken place.” Kotteakos, 328 U.S. at 774; Brooks, 164
F.2d at 143 (“[T]he trial was conducted too much on the apparent assumption that . . . evidence as
to what any of the defendants said or did would be admissible against all of the others.”).
C. Vargas-Ocampo Does Not Remedy the Government’s Fifth Amendment Violation
In its objections to Ms. Hockridge’s proposed jury instructions, the Government argued
that Ms. Hockridge could be convicted if the evidence were merely “equally consistent with Ms.
Hockridge’s guilt as it is with her innocence,” and that Ms. Hockridge’s proposed instruction to
the contrary “tracks the ‘equipoise rule,’ which the Fifth Circuit has explicitly abandoned.” Agreed
Charge (Doc. #143) at 15 & n.4 (citing United States v. Vargas-Ocampo, 747 F.3d 299, 300–01
(5th Cir. 2014) (en banc)). To the extent the Government argues Ms. Hockridge could be convicted
if the Government provided evidence consistent with a single conspiracy rather than sufficient to
allow the jury to find a single conspiracy beyond a reasonable doubt, the Government has
misapplied Vargas-Ocampo.
The Government’s error in reasoning is its conflation of the fact-finding standard at the
trial stage with the standard of postconviction appellate review on a sufficiency-of-the-evidence
challenge. Vargas-Ocampo held that appellate courts should not reverse a conviction on the
grounds that “the evidence construed in favor of the verdict gives equal or nearly equal
circumstantial support to a theory of guilt and a theory of innocence of the crime charged.” 747
F.3d at 301 (quotation omitted). In context, this holding merely instructs reviewing courts not to
make credibility judgments “on a cold appellate record without the benefit of the dramatic insights
gained from watching trial.” Id. But Vargas-Ocampo did not, and could not, hold that a fact-finder
could convict a criminal defendant on the basis of evidence the fact-finder believed was equally
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probative of guilt or innocence—i.e., it did not lower the reasonable doubt standard below a
preponderance standard. See id. at 302 (holding that, notwithstanding the court’s rejection of the
“equipoise” rule, “courts remain empowered to consider . . . whether the inferences drawn by a
jury were rational, as opposed to being speculative or insupportable, and whether the evidence is
sufficient to establish every element of the crime”). Because the evidence here would not permit a
“rational trier of fact [to find] the essential elements of [Count One] beyond a reasonable doubt”—
including the existence of a single conspiracy—Ms. Hockridge is entitled to a judgment of
acquittal. See United States v. Capistrano, 74 F.4th 756, 166 (5th Cir. 2023) (citing Vargas-
Ocampo, 747 F.3d at 303).
D. The Government Failed to Prove Beyond a Reasonable Doubt That Ms.
Hockridge Knowingly Agreed to Join Any Conspiracy
In addition to failing to prove the unified conspiracy charged in the Superseding Indictment,
the Government also failed to prove beyond a reasonable doubt that Ms. Hockridge agreed to join
any conspiracy at all. That failure likewise requires a judgment of acquittal on Count One.
To establish conspiracy, “there must be proof beyond a reasonable doubt that a conspiracy
existed, that the accused knew it and, with knowledge, voluntarily joined it.” United States v. White,
569 F.2d 263, 266–67 (5th Cir. 1978) (citation). “Without an agreement, there is no conspiracy.”
Ganji, 880 F.3d at 768 (citation omitted). “[P]roof of an agreement to enter into a conspiracy is
not to be lightly inferred.” White, 569 F.2d at 267 (cleaned up); see also Ganji, 880 F.3d at 767–
68. Nor is “conscious parallelism or parallel business conduct” sufficient on its own to prove an
agreement to join a conspiracy. United States v. Holloway, 377 F. App’x 383, 387–88 (5th Cir
2010) (cleaned up). Moreover, one “cannot negligently enter into a conspiracy”; the Government
must prove that the defendant “knowingly agreed to participate in a common scheme to meet an
unlawful goal.” Ganji, 880 F.3d at 776.
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Based on the evidence adduced during the Government’s case-in-chief, a rational trier of
fact could not conclude beyond a reasonable doubt that Ms. Hockridge knowingly agreed to join
any conspiracy to facilitate fraudulent PPP loan applications. The evidence repeatedly distanced
Ms. Hockridge from any such conspiracy. For example, Mr. Flores testified that Nathan Reis kept
Ms. Hockridge at a distance because of a disagreement over how to operate Blueacorn, 6/12 Tr.
224:15–226:15; that Ms. Hockridge was not part of the original pitch that Mr. Reis made to Mr.
Flores about the Blueacorn idea, 6/12 Tr. 128:22–129:2; that, although Mr. Flores spoke with Mr.
Reis often, Ms. Hockridge was often not around, 6/12 Tr. 156:21–157:4; and that, though Mr. Reis
and Mr. Cota helped Mr. Flores complete a fraudulent loan application, Ms. Hockridge was not
involved in changing any number on the application, 6/12 Tr. 175:25–176:13. Nor did the
Government present any evidence that Ms. Hockridge knew that any information on Mr. Flores’s
applications were false. Instead, as Mr. Flores testified, “Ms. Hockridge was kept in the dark” by
Mr. Flores and Mr. Reis. 6/13 Tr. 274:14–274:19. As explained above, moreover, Mr. Hochberg
similarly placed Ms. Hockridge at a distance from any fraud, which underscores that Ms.
Hockridge could not have knowingly joined a conspiracy to commit fraud.
More to the point, a rational factfinder must conclude that Ms. Hockridge took steps to root
out fraudulent applications—thus undermining the very conspiratorial goals the Government
ascribes to her. For example:
• Ms. Hockridge hired attorneys named the Warzels—one of whom was a
prosecutor—to review loan applications. 6/13 Tr. 194:21–194:5.
• Special Agent Friedemann admitted he has seen documents showing that Ms.
Hockridge and others stopped potentially fraudulent loan applications, 6/13 Tr.
156:23–157:4, and that Ms. Hockridge had conversations about preventing fraud,
6/13 Tr. 173:23–174:17.
• Ms. Hockridge removed almost one hundred loans from the VIPPP system when
she discovered that they were connected with a known fraudster under the alias
“Rick Diamond.” 6/16 Tr. 95:22–95:24, 197:10–197:19.
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Perhaps most perniciously, the Government evidently seeks to have the jury infer merely
from Ms. Hockridge’s marriage to her husband Nathan Reis that she was aware of his revisions to
various borrowers’ Schedule Cs and 1099s—despite the lack of any evidence of any
communications reflecting such knowledge, and despite the Government’s having combed
through thousands of pages of their confidential marital communications. 2 But a “conspiracy
2
The sole exception the Government has introduced is a message Ms. Hockridge sent to Mr.
Reis regarding an application for C.B. being rejected because “your photoshop skills weren’t very
good.” That statement is insufficient to sustain a conviction beyond a reasonable doubt for a host
of reasons.
First, the timing of the message indicates that, even drawing all reasonable inferences in favor
of the Government, Ms. Hockridge learned of the revision to the 1099 after it had been submitted.
As this Court will instruct the jury, “Mere presence at the scene of an event, even with knowledge
that a crime is being committed, . . . does not necessarily establish proof of the existence of a
conspiracy.” Proposed Charge (Doc. #142) at n.34 (emphasis added); cf. Ganji, 880 F.3d at 776
(“Again, to prove conspiracy, the Government must prove beyond a reasonable doubt that the
defendant knew of and participated in an agreement to commit a crime. It is not enough that the
Government proves that the defendant knew something criminal was afoot.”).
Second, the Government has not presented evidence that the number in the revised 1099 was
not a true number, much less not a reasonable estimate of Mr. Sanor’s earnings. As several
Government witnesses—including Mr. Flores and Special Agent Friedemann—all acknowledged,
multiple borrowers had indicated to Mr. Flores and others that what they had reported to the IRS
previously as their income had been understated, and, in the context of a sole proprietorship or
self-employed individual, whether money received from one’s business should be reported on a
1099, as profit on a Schedule C, or as a distribution to a shareholder was well within the taxpayer’s
discretion (and are all economically equivalent for tax purposes for any pass-through entity). See,
e.g., 6/12 Tr. 243:17–244:13; 6/13 Tr. 197:6–197:10.
Finally, even if it were permissible to infer from the mere revision to such a document that the
revised document (as opposed to the original document) is false, the Government has introduced
absolutely no evidence that Ms. Hockridge was aware that the revised number was not at least a
fair estimate of Mr. Sanor’s income, or that the documents supporting his application were not true
and accurate in “all material respects.” See Ex. 79A at 2. Since Mr. Sanor would have received the
same loan so long as his income was more than $100,000, Mr. Sanor’s estimate could have been
off by as much as $57,000 and still not be a “material” falsehood. Nor is there any dispute that, as
a matter of law, taxpayers are permitted both to amend their returns to correct incorrect information
and to file revised 1099s within three years after the submission of their original tax documents.
6/13 Tr. 279:14–21.
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cannot be proven solely by family relationship or other types of close association . . . . Mere
similarity of conduct among various persons and the fact that they have associated with or are
related to each other do not establish the existence of a conspiracy.” United States v. White, 569
F.2d 263, 268 (5th Cir. 1978) (citations omitted); see also United States v. Skillern, 947 F.2d 1268,
1273 (5th Cir. 1991) (finding the evidence was insufficient to sustain a conspiracy conviction
where the evidence showed nothing more than “that [defendant] associated with members of a
drug conspiracy and that one member of that conspiracy speculated that [defendant] might be a
member of that conspiracy”). The insinuation that, because Ms. Hockridge and Mr. Reis were
married and business partners, is at best the sort of mere “speculation” that is insufficient to sustain
proof of guilt beyond a reasonable doubt. Ganji, 880 F.3d at 767 (cleaned up).
The Government also expects the jury to infer that Ms. Hockridge agreed to join a
conspiracy based on testimony that she was around supposed fraud. See Gov’t Filing Concerning
Deliberate Ignorance (Doc. #214) (arguing that Ms. Hockridge was deliberately ignorant “to the
fraud swirling around her” (emphasis added)). For example, Mr. Flores testified that Ms.
Hockridge was in the room when her husband, Mr. Reis, allegedly told borrowers they could
falsify loan applications (of which Mr. Flores could not provide any examples). (6/12 Tr. 68:3–
68:13). But “[a] conspiracy may not be shown . . . by evidence that merely places the defendant in
a climate of activity that reeks of something foul.” United States v. Boyd, 478 F. App’x 826, 829
(5th Cir. 2012) (cleaned up)); see also Jury Charge at 14 (“Mere presence at the scene of an event,
even with knowledge is being committed . . . does not necessarily establish proof of the existence
of a conspiracy.”)
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The Government also relies heavily on the uncorroborated testimony of Eric Karnezis, but
a rational factfinder could not find Mr. Karnezis’s testimony sufficiently credible to reach a guilty
verdict beyond a reasonable doubt. Mr. Karnezis is, indisputably, a serial liar:
• When he was initially arrested, Mr. Karnezis admits that—contrary to this trial
testimony—he told federal agents that Mr. Reis and Ms. Hockridge were on the up
and up and had a system to catch fraud. 6/16 Tr. 77:15–77:21.
• He also admitted lying to agents about the first month of his work on VIPPP being
legitimate. 6/16 Tr. 154:1–154:6.
• He lied to Mr. Reis about how many employees his business had. 6/16 140:18–
140:23, 155:10–155:16֪.
• He submitted loan-application paperwork to Ms. Hockridge without disclosing to
her that he was lying about the size of his businesses. 6/16 Tr. 156:17–156:19.
• He lied to Ms. Hockridge about how many employees an applicant had. 6/16 Tr.
206:20–206:25.
• He pretended to disassociate with a fraudster despite continually associating with
that same fraudster. 6/16 Tr. 209:7–209:23.
• Although Ms. Karnezis contends he conspired with Ms. Hockridge to commit fraud,
he has no written communications to that effect—despite having messages
discussing fraud with Mr. Reis. 6/16 197:20–198:10.
• Mr. Karnezis provided false excuses to Ms. Hockridge for suspicious aspects of the
loan applications he submitted. Ex. 35A, at 24-25; 6/19 Tr. 138:4-17.
In short, this lone witness is insufficient to support a verdict beyond a reasonable doubt.
See United States v. Nicosia, 360 F. Supp. 814, 819 (N.D. Ind. 1973) (“Such affirmative evidence,
together with the evidence of defendant’s lifetime of good works and excellent reputation, refutes
the uncorroborated and impeached testimony of the Government’s lone witness against defendant
as to the alleged payments.”); cf. United States v. Taglia, 922 F.2d 413, 415 (7th Cir. 1991) (“If
the government’s case rested entirely on the uncorroborated testimony of a single witness who was
discovered after trial to be utterly unworthy of being believed because he had lied consistently in
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a string of previous actions, the district judge would have the power to grant a new trial in order
to prevent an innocent person from being convicted.”).
E. The Government Failed to Prove Beyond a Reasonable Doubt That Ms.
Hockridge Submitted a Knowingly False Loan Application for Body Politix LLC
The centerpiece of the Government’s theory that Ms. Hockridge was part of a PPP fraud
conspiracy is the allegation that Ms. Hockridge submitted a fraudulent loan application for Body
Politix in June 2020. Superseding Indictment (Doc. #163) ¶ 17(c). The evidence, however, would
not allow the jury to find Ms. Hockridge guilty beyond a reasonable doubt as to that loan
application. The uncontroverted evidence presented at trial shows that Ms. Hockridge did prepare
that loan application, which was instead drafted and submitted by Mr. Reis. See Ex. 27A at 1–2
(Mr. Reis asking borrower if he can be an employee of Body Politix to increase the PPP loan
amount). Likewise, the Government did not show any evidence from which a jury could conclude
that Ms. Hockridge knew of any material falsehoods in the June 2020 loan application at the time
the application was submitted. Instead, the Government has merely presented evidence of that Ms.
Hockridge discussed the loan application with an underwriter at Prestamos after the loan was
submitted—a discussion which omitted any mention of the amounts on the loan application the
Government (incorrectly) contends to be false. See Ex 64H at 16.
To prove conspiracy, the Government must “prove beyond a reasonable doubt that the
defendant knew of and participated in an agreement to commit a crime. And it ‘is not enough that
the Government proves that the defendant knew something criminal was afoot.” Ganji, 880 F.3d
at 766. Because the Government did not present any evidence to show that Ms. Hockridge knew
of any decision to make material, false statements on the June 2020 loan application at the time
the application was submitted, she could not have agreed to or knowingly assisted in facilitating
the false loan application. Thus, once again, the sum total of the Government’s positive evidence
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on this point is Ms. Hockridge’s general association with Mr. Reis (i.e., her husband). But “[m]ere
similarity of conduct among various persons and the fact that they have associated with or are
related to each other is insufficient to prove an agreement.” Id. at 767–78; White, 569 F.2d at 268
(holding that a “conspiracy cannot be proven solely by family relationship or other types of close
association” (citation omitted)).
But the Government’s failure of proof with respect to the 2020 Body Politix application
does not stop there. First, the Government failed to produce any evidence to demonstrate that the
loan application was materially false. As several of the Government’s witnesses agreed, any
income reported above $100,000 for a sole proprietor like Body Politix did not affect the size of
the loan that Body Politix could receive. 6/16 Tr. 273:1–273:6; 6/12 Tr. 149:2–149:19. Second, as
the evidence showed, Ms. Hockridge did in fact have more than $192,000 in deposits into her
“work” account at Wells Fargo, which, as Special Hagerman acknowledged, she was permitted to
use for Body Politix business. 6/18 Tr. 34:24–36:24; 42:20–42:23; Ex. 63B. Finally, the
Government did not present any evidence that Ms. Hockridge had an adequate understanding of
tax law to know that $96,000 deposited into her “work” account would not qualify as “gross
receipts” on a Schedule C.
Similar problems confront the Government as to the “doctored” Wells Fargo bank
statement submitted with the Body Politix loan. First, there is no dispute that Body Politix was an
existing entity at the time of the 2020 application, having been incorporated in 2016—and the only
material purpose for the inclusion of a bank statement was to confirm that aspect of a borrower’s
eligibility. 6/17 Tr. 178:2-178:3; 226:6-226:7. Second, as Special Agent Hagerman acknowledged,
the Government produced no evidence that Ms. Hockridge (as opposed to Mr. Reis) made the
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alteration to the statement. 6/18 Tr. 58:2-59:5. Finally, the Government presented no evidence that
Ms. Hockridge ever reviewed the altered bank statement prior to its submission by Mr. Reis.
Those failures of proof likewise infect the Government’s charge under Count Four, which
pertains to the 2021 Body Politix loan. Each of the foregoing flaws in its theory for the knowing
falsity of the 2020 loan apply equally to the 2021 loan, but in that case, not even the Government
claims that Ms. Hockridge submitted or prepared that loan. Instead, as Special Agent Hagerman’s
summary slides demonstrated, the 2021 loan was indisputably submitted by Ms. Hockridge’s
husband. Ex. 65B; Ex. 76E, at 3. Thus, the Government has not produced any evidence from which
a rational jury could conclude beyond a reasonable doubt that Ms. Hockridge “caused” the
transmission of the wire described in Count Four.
F. The Government Failed to Prove a Pattern of Materially False Loan Applications
To demonstrate a pattern consistent with a conspiracy, the Government introduced
testimony through its witnesses about a number of PPP loan applications that Ms. Hockridge
helped facilitate. But it did not introduce evidence from which a reasonable factfinder could
conclude, beyond a reasonable doubt, that those loan applications included materially false
statements about the applicant’s income or financial status. Absent such proof, this supposed
pattern is little more than a scatterplot of disconnected data—there is no through-line establishing
a conspiracy beyond a reasonable doubt.
With respect to loan applications submitted during PPP Round 1, the Government’s
evidence of false statements was that Blueacorn customers’ loan applications listed different
business payroll than what was reported on their business tax returns. But the Government did not
present any evidence of which of the two documents was inaccurate. Indeed, as Special Agent
Friedmann acknowledged, some borrowers affirmatively told the Government that the number on
their loan application was correct, and the evidence showed that many taxpayers underreport
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business income to the IRS. 6/12 Tr. 243:13-16. For none of these allegedly fraudulent loans did
the Government subpoena (much less introduce at trial) bank records that would have
demonstrated which of the applicants’ reports of their business payroll was the correct one. In
other words, the only evidence the Government introduced shows that some numbers on the
borrowers’ applications and their tax documents were different—not that the numbers in the
applications were false. As to PPP Round 1, a rational fact finder could not find beyond a
reasonable doubt that Ms. Hockridge submitted applications containing false information as to
these borrowers. Some examples illustrate the point:
• Steven Sampang: The Government introduced evidence that Mr. Sampang claimed an
annual income of $161,000 on his Schedule C. 6/13 Tr. 151:18–151:20. This would be
consistent with Ms. Hockridge’s observation that his “bank statement show[ed] hefty
deposits.” Id. at 151:1–151:9; Ex. 4D. While Mr. Sampang told Ms. Hockridge that he’d
received only a single 1099 in 2019 for his photography business, reflecting under $600 in
income, 6/13 Tr. 74:19–74:22,3 the Government never introduced any evidence of what
Mr. Sampang’s actual income was. And as the Government’s witnesses acknowledged, it
is common for independent contractors and sole proprietors to receive income without
receiving an accompanying 1099 from their customers. 6/18 Tr. 86:5-18. Yet Special Agent
Friedemann never subpoenaed Mr. Sampang’s bank statements to determine his income,
had not “look[ed] thoroughly through the bank statement to determine where the income
is coming from,” and did not even contact Mr. Sampang about his application until April
of 2025. Id. at 154:9–154:25; 238:12–239:3 (“Q: So as you’re sitting here today, you can’t
tell us whether what Mr. Sampang told Ms. Hockridge is true or false? A: That is correct.”).
In other words, the Government did not provide any evidence that Mr. Sampang’s business
income was less than $161,000, so it did not establish that Ms. Hockridge submitted a false
statement on his PPP loan application.
• Oliver O’Connell: Mr. O’Connell worked with Mr. Reis—not Ms. Hockridge—to submit
a PPP loan application in 2020, which estimated $180,000 in independent contractor
income. When interviewed during the course of the Government’s investigation, Mr.
O’Connell told the Government that $180,000 was “close” to what he actually made in
2019. 6/13 Tr. 192:13–192:16. But the Government did not establish what Mr. O’Connell’s
true income was, and Special Agent Friedemann again testified that he “d[idn’t] know
whether [Mr. O’Connell] lied to Mr. Reis or if he lied to [Special Agent Friedemann].” Id.
at 195:15–195:16. Put simply, a reasonable factfinder cannot treat a confession of
ignorance as evidence of falsehood.
3
This hearsay is inadmissible to prove the truth of the matter asserted.
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• Mark Sanor: The Government’s evidence as to Mr. Sanor was that a PPP loan application
submitted by Blueacorn showed an independent contractor income one hundred thousand
dollars larger than a 1099 he had received, with supporting documentation that had
apparently been altered. 6/13 Tr. 15:16–15:19, 22:20–23:2. When the application with the
altered income numbers was submitted to a bank and subsequently rejected, Ms. Hockridge
texted Mr. Reis, “I know why Lendistry denied his application. Your Photoshop skills
aren’t very good.” 6/13 Tr. 25:10–25:17. However, Special Agent Friedemann conceded
that the Govnerment had no evidence Ms. Hockridge ever opened the files (much less that
she opened them prior to submitting the loan application), id. at 294:10–294:13, and that
he had no personal knowledge as to how much Mr. Sanor had actually earned in 2019
because he had not done anything to verify the numbers, id. at 197:25–198:5. Even
construed in the light favorable to the Government, this evidence at most shows that Ms.
Hockridge believed after the fact that Mr. Reis had altered Mr. Sanor’s 1099 to submit to
the SBA. It does not show that Mr. Sanor actually did not earn more income and that the
application contained a false statement. As Mr. Flores and Special Agent Friedemann also
conceded, some PPP borrowers had previously been reporting their income inaccurately to
the IRS (because falsely reporting a lower income to the IRS would result in less taxes, but
truthfully reporting such income on a PPP loan application could result in a larger loan).
See 6/12 Tr. 243:17–244:13; 6/13 Tr. 197:6–197:10. Special Agent Friedemann did not
interview Mr. Sanor to determine his true income.6/13 Tr. 200:15–200:17.
These examples illustrate a common theme: the Government seeks to prove fraudulent
misstatements from nothing more than discrepancies between documents submitted to the IRS and
documents submitted to obtain PPP loans. But the Government did not present any evidence
showing which documents were true and which were false. As a result, with the evidence presented,
to find the borrowers’ PPP applications false, the jury would have to speculate as to which
documents were accurate; it could not rationally conclude, beyond a reasonable doubt, that Ms.
Hockridge submitted any false statements to financial institutions on those applications.
II. The Government Failed to Prove the Wire Fraud Charges Beyond a Reasonable Doubt
The Government has likewise failed to prove Counts Two through Five of the Superseding
Indictment beyond a reasonable doubt. Like the conspiracy charge, the Government failed to
provide a single, unified scheme to defraud and thus deviated from the Superseding Indictment in
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violation of the Fifth Amendment. The Government also failed to prove, beyond a reasonable
doubt, that Ms. Hockridge knew that any loan application was materially false.
A. The Government Failed to Prove a Unified Scheme to Defraud
As explained above, the Fifth Amendment requires the Government to prove the
allegations and charges in the Superseding Indictment, rather than seek a conviction based on
unindicted charges or allegations. Here, the Superseding Indictment’s wire fraud counts (Two
through Five) allege a single, unitary scheme to commit wire fraud that overlaps with the single,
unitary conspiracy charged in Count One. Superseding Indictment (Doc. #163) ¶ 19 (alleging that
Defendants, Coconspirator-1, and others “devised and intended to device the scheme to defraud
describe in paragraphs 15 through 17”). The Government was therefore obligated to prove that
unitary scheme to defraud, not multiple courses of conduct. See United States v. Camiel, 689 F.2d
31, 36 (3d Cir. 1982) (holding that, unlike for a conspiracy charge, “it is the existence of a common
scheme, and not any agreement among the parties to participate in it, that is critical” for a mail
fraud charge). Yet, for the reasons identified above, “the [G]overnment’s evidence, when viewed
in the light most favorable to the [G]overnment, was insufficient for a rational juror to conclude
beyond a reasonable doubt [that Ms. Hockridge and others] had devised or culpably participated
in the unitary scheme to defraud alleged in the [Superseding] Indictment.” United States v.
Gengler, No. 1:08-cv-12, 2009 WL 5549225, at *17 (E.D. Va. Oct. 23, 2009).
For the same reasons identified above, the Government’s decision to charge one unified
scheme but prove multiple courses of conduct prejudiced Ms. Hockridge, which warrants a
judgment of acquittal. See id. at *19–20. In particular, the Superseding Indictment’s unified-
scheme charge caused the admission evidence from a 2020 course of conduct that would not have
been admissible against Ms. Hockridge if the Government had charged only the scheme relevant
to her. See Camiel, 689 F.2d at 38 (holding that alleging one unified scheme but proving multiple
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causes a “spillover of evidence”); see also id. at 39 (describing the prejudice resulting from the
spillover of evidence). For that reason, the Court should enter a judgment of acquittal on the
remaining counts of the Superseding Indictment.
B. The Government Failed to Prove that Ms. Hockridge Knew That PPP Loan
Applications Were Materially False
1. The Jury Cannot Rationally Conclude That Any False Statement was Material
The Government must prove in wire fraud cases that the underlying representations are
materially false. United States v. Velencia, 600 F.3d 389, 426 n.11 (5th Cir. 2010) (citing Neder v.
United States, 527 U.S. 1, 25 (1999) (holding that materiality is a distinct element of wire fraud)).
A representation or statement is “material” if it has a natural tendency to influence, or is capable
of influencing, the decision of the person or entity to which it is addressed. As the Supreme Court
recognized in Universal Health Services v. United States ex rel. Escobar, where “the Government
regularly pays a particular type of claim in full despite actual knowledge that certain requirements
were violated, and has signaled no change in position, that is strong evidence that the requirements
are not material.” 579 U.S. 176, 195 (2016). While Escobar discussed the meaning of materiality
under the False Claims Act, the Supreme Court explained that the definition of materiality under
that statute was the same as other federal fraud statutes, including, as relevant here, the wire fraud
statute. Id. at 192–93. Moreover, as the Supreme Court recently held, the wire-fraud statute’s
“‘demanding’ materiality requirement substantially narrows the universe of actionable
misrepresentations.” Kousisis v. United States, 145 S. Ct. 1382, 1398 (2025) (citing Universal
Health Services, 579 U.S. at 194)).
Here, even if a reasonable factfinder could infer (rather than simply speculate) that Ms.
Hockridge made or caused false statements on a PPP loan application, the Government’s evidence
would not allow the conclusion, beyond a reasonable doubt, that any such misstatement was
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material. The possibility of fraud in PPP loan applications was obvious. See 6/16 Tr. 298:19–
298:21. Yet the Government imposed minimal underwriting standards on lenders. See 6/16 Tr.
224:2–224:7. Accordingly, any misstatements made during the loan application process regarding
adherence to the PPP’s requirements were not material to the Government’s decision to issue PPP
loans because the Government knew or was aware that such misstatements were being regularly
made but issued the loans anyway.
Moreover, as explained above, because reported earnings over $100,000 could not have
increased the loan amount, the Government cannot demonstrate that any false statements of
income in excess of $100,000 are material. 6/16 Tr. 273:1–273:6.
2. The Government Failed to Prove Knowledge or Intent
Even there were evidence that Ms. Hockridge made or caused materially false statements
in loan applications, a rational jury could not reasonably conclude beyond a reasonable doubt that
Ms. Hockridge did so with knowledge that the statements in any such loan applications were false
at the time the applications were submitted. Because a knowing falsehood is a sine qua non of wire
fraud, the Government’s failure in this regard renders its proof on Counts Two through Five
insufficient as a matter of law.
“Good faith is a complete defense to the crime of wire fraud if the defendant did not act
with the intent to defraud. . . . The essence of the good faith defense is that one who acts with
honest intentions cannot be convicted of a crime requiring fraudulent intent.” Proposed Jury
Instruction (Doc. #143) No. 26. Here, the Government has not presented evidence sufficient for a
rational factfinder to find it beyond a reasonable doubt that Ms. Hockridge did not act in good faith
when working for Blueacorn and operating VIPPP. Quite the opposite: as detailed above, the
evidence overwhelmingly shows that she attempted to root out fraudulent PPP loan applications—
even though no rule or regulation required her to do so. See, e.g., 6/13 Tr. 156:23–157:4; 173:23–
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174:17; 194:21–194:5; 6/16 Tr. 95:22–95:24, 197:10–197:19; Ex. 35A, at 24-25; 6/19 Tr. 138:4-
17.
The Government has introduced evidence of multiple fraudulent loans applications that
borrowers submitted through Blueacorn or VIPPP. But Ms. Hockridge’s failure to identify every
false statement in every bad loan application does not demonstrate beyond a reasonable doubt that
she acted with fraudulent intent. To the contrary, under the PPP regulations, she, like the lenders
to whom the applications were submitted, was entitled to rely on the borrowers’ certifications that
they were telling the truth. See, e.g., 6/16 Tr. 225:25–226:6. The Government also promised that
lenders would be held harmless for any falsehoods in the loan application or the applicant’s
supporting documentation. 6/16 Tr. 242:11–242:17.4 As the evidence adduced at trial showed, Ms.
Hockridge acted as a referral source both to lenders and to Fin Cap, a lender service provider, in
exchange for a portion of the statutorily provided lender fee, entitling her to the protections
promised to such entities by Congress. 6/13 Tr. 242:11-17. As a result, Ms. Hockridge was entitled
to rely, like the lenders she served, on the certifications of borrowers that their loan applications
were true and accurate “in all material respects,” and she was promised that she would be “held
harmless” from liability for their misstatements so long as she acted in good faith. Allowing a
conviction to stand on such a basis would vitiate the clear mandate of Congress, that borrowers,
4
Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act, Pub. L. 116-
260, §305, 134 Stat. 1182, 1996–97 (Dec. 27, 2020) (codified at 15 U.S.C. § 636m(h)(2)) (“HOLD
HARMLESS . . . A lender may rely on any certification or documentation submitted by an
applicant for an initial or second draw PPP loan . . . .” (emphasis added)); Business Loan Program
Temporary Changes; Paycheck Protection Program as Amended by Economic Aid Act, 86
Fed. Reg. 3692, 3694–95, 3708 (Jan. 14, 2021) (“SBA will allow lenders to rely on certifications
of the borrower in order to determine eligibility of the borrower and use of loan proceeds and to
rely on specified documents provided by the borrower to determine qualifying loan amount and
eligibility for loan forgiveness. Lenders must comply with the applicable lender obligations set
forth in this interim final rule, but will be held harmless for borrowers’ failure to comply with
program criteria . . . .” (emphasis added)).
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and not those assisted lenders in processing their applications, would be held responsible for any
material falsehoods in borrower applications.
True, the Government introduced testimony from Mr. Hochberg that he submitted
fraudulent loan applications in 2020 and 2021, with help from Mr. Reis and Ms. Hockridge. 6/16
Tr. 310:10–310:23. But a rational factfinder could not conclude beyond a reasonable doubt that
Ms. Hockridge knew that applications associated with Mr. Hochberg were fraudulent. Mr.
Hochberg repeatedly distanced Ms. Hockridge from fraud. See, e.g., 6/17 Tr. 27:21–27:24
(testifying that he did not speak with Ms. Hockridge about the fraud he was committing in his first
PPP loan); id. 33:4–34:9 (testifying that he did not tell Ms. Hockridge about his business’s
financial status for his 2020 loan application); id. 56:16–20 (“Q: You don’t think you qualified for
this loan [in 2020]? . . . A: I don’t think so, no. Q: All right. Is that something you told Stephanie
[Hockridge]? A: No.”); id. 66:19–20 (testifying that second loan application “did not involve Ms.
Hockridge”); id. 78:10–12 (testifying that he never told Ms. Hockridge his payroll documents were
false regarding his 2021 loan application); id. 83:4–83:11(testifying that he does not recall
anything specifically that he said in front of Ms. Hockridge about committing fraud); id. 96:13–
96:16 (testifying that he does not recall any communication with Ms. Hockridge where she
instructed him to falsely state that any referral’s income was $100,000); id. 106:6-106:9 (testifying
that he did not talk openly in front of Ms. Hockridge about any fraud); id. 146:10-146:21 (testifying
that he did not tell Ms. Hockridge that any information was false in the loan applications he
submitted or that were submitted on behalf of his friends).
The Government also submitted testimony of IRS Special Agent James Hagerman,
attempting to prove that Ms. Hockridge submitted a fraudulent loan application for Body Politix
in 2021. But as Special Agent Hagerman conceded, Mr. Reis and A.T. discussed the loan without
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including Ms. Hockridge on the communication. 6/18 Tr. 27:7–28:25; GX76E at 3, 5. He also
admitted that he has seen no corroborating evidence showing that Ms. Hockridge was sent the
application materials before they were submitted or that she caused the application to be sent. 6/18
Tr. 30:9–15; 31:9–22. All Special Agent Hagerman could say is that he “believe[d] there is
evidence that, upon reading it, made [him] believe that Ms. Hockridge did participate in [the]
application.” Id. 29:25–30:5. Believe he may, but Special Agent Hagerman’s beliefs—beliefs he
apparently formed from reading documents and communications that he conceded had nothing to
do with Ms. Hockridge—are not evidence of Ms. Hockridge’s guilt, and certainly would not dispel
a reasonable doubt. Cf. United States v. Morris, 568 F.2d 396, 401 (5th Cir. 1978) (noting that “an
attorney’s statement of his beliefs injects into the case irrelevant or inadmissible matter or facts
not legally produced into evidence”). If Mr. Hagerman had evidence that substantiated his beliefs,
he should have pointed to it. He did not. As a result, the Government failed to prove beyond a
reasonable doubt that Ms. Hockridge knew about falsehoods in any loan applications it introduced
at trial. For these reasons, the Court should enter a judgment of acquittal on the wire fraud charges.
C. The Government Has Failed to Prove That Ms. Hockridge “Caused” Any of the
Wire Transfers Described in Counts Two Through Five
As explained above, the Government has failed to prove that Ms. Hockridge had any
involvement in the submission of the 2021 Body Politix loan charged as Count Four. To the
contrary, the Government’s evidence plainly demonstrates that that loan application was prepared
and submitted by Ms. Hockridge’s husband with the assistance of A.T. As such, there is simply
no evidence that Ms. Hockridge caused the submission of the loan application that resulted in the
wire transfer described in Count Four.
Counts Two, Three, and Five are likewise infirm. Each of those counts relates to a loan
application submitted on behalf of Devin Hochberg. The Government has not submitted evidence
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capable of persuading a rational jury that she caused his applications to be submitted, thus
rendering its proof on that element insufficient.
III. The Government Has Failed to Prove Venue on Any of the Counts
A. The Government Failed to Prove Venue Is Proper for the Conspiracy Count,
Thereby Entitling Ms. Hockridge to Acquittal on That Count
In any criminal case, “the Government has the burden of establishing venue.” United States
v. Fells, 78 F.3d 168, 170 (5th Cir. 1996) (citing United States v. Winship, 724 F.2d 1116, 1124
(5th Cir. 1984)). Both the Constitution and the Federal Rules of Criminal Procedure guarantee that
a defendant will be tried in the state and district where the crime is alleged to have been committed.
See U.S. Const. amend. VI (“In all criminal prosecutions, the accused shall enjoy the right to . . .
trial, by an impartial jury of the State and district wherein the crime shall have been committed,
which district shall have been previously ascertained by law.”); Fed. R. Crim. P. 18 (“Unless a
statute or these rules permit otherwise, the government must prosecute an offense in a district
where the offense was committed.”). Where a defendant faces multiple counts, the Government
must prove venue is proper as to each of them. See United States v. Davis, 666 F.2d 195, 198 (5th
Cir. 1982) (“Venue may properly be laid in one district with respect to one count of an indictment,
but still be improper with respect to the other counts.”) (citation omitted).5
Because the question of what acts constitute the “commission” of an offense, “the venue
inquiry is intimately tied to the offense charged.” United States v. Strain, 396 F.3d 689, 693 (5th
Cir. 2005); see also id. (“[T]he venue inquiry hinges to a large extent on how we define the
offense.”). “In cases involving conspiracy offenses, venue is proper in any district where the
5
The Government must establish venue for each count by a preponderance of the evidence.
United States v. Strain, 396 F.3d 689, 692 n.3 (5th Cir. 2005).
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agreement was formed or an overt act occurred.” United States v. Thomas, 690 F.3d 358, 369 (5th
Cir. 2012) (quoting United States v. Garcia Mendoza, 587 F.3d 682, 686 (5th Cir. 2019)).
Here, the Government cannot establish venue over the conspiracy count against Ms.
Hockridge. Not once in this case has the Government presented any evidence (1) that the
conspiracy charged was formed in the Northern District of Texas or (2) that an overt act in
furtherance of that conspiracy was committed by a coconspirator within the Northern District of
Texas. Cf. United States v. Owens, 724 F. App’x 289, 295–96 (5th Cir. 2018) (holding that
Northern District of Mississippi was an improper venue for charging conspiracy to distribute
methamphetamine where evidence only showed acts by the defendant in the Southern District of
Mississippi).
To the contrary, the Government’s evidence relates to acts that occurred in Arizona, where
Ms. Hockridge lived at all times relevant to the events alleged in the Superseding Indictment. For
example, Mr. Flores testified that at all relevant times, (i.e., “[d]uring Covid-19”), “it was no
traveling [s]o it was all phone calls and emails.” 6/12 Tr. 62:16–62:22. At most, the evidence
showed that loan proceeds were disbursed by a bank in the Northern District of Texas—but that
was not an affirmative act by Ms. Hockridge or any coconspirator, so it cannot provide an
evidentiary hook to establish proper venue here. See Strain, 396 F.3d at 694 (explaining that
“circumstance elements” of an offense, such as knowledge or acts by a third party that “do not
involve any proscribed conduct by the accused” cannot “serve as a basis for establishing venue”);
United States v. Rodriguez-Lopez, 756 F.3d 422, 430 (5th Cir. 2014) (“Venue is proper in
conspiracy offenses in any district where the agreement was formed or an overt act occurred.”
(cleaned up)); see id. (holding that “[v]enue may be proper in districts in which conspirators have
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never set foot” if “acts committed by coconspirators in furtherance of the conspiracy” took place
in the district) (emphasis added) (cleaned up)).
Perhaps recognizing the weakness in its position, the Government elicited testimony from
Mr. Flores that Mr. Reis sent one text message from an airport in Dallas, in which Mr. Reis asked
Mr. Flores to confirm that Mr. Flores should attract customers through “a multitiered partner
network.” 6/12 Tr. 112; GX 27A, at 18. But this text message was not an overt act in furtherance
of a conspiracy. Nothing in the text message itself suggests any connection to criminal activity.
And as Mr. Flores himself testified, Blueacorn had legitimate operations that were separate and
apart from any conspiracy between Mr. Reis and Mr. Flores regarding their own loan applications.
See 6/12 Tr. 212:13-212:18 (testifying that legitimate borrowers would sometimes get caught up
in underwriting); id. 213:12-213:17 (testifying that his job at Blueacorn included helping banks
understand and resolve issues for legitimate loans); id. 243:7-243:12 (testifying that part of his job
was to help legitimate borrowers understand how to structure their loans correctly).
Even then, all the message shows is confirmation of an act that had already been agreed to
and which had not yet been performed. To accept such a statement as an “act in furtherance of a
conspiracy” would stretch those words well beyond their plausible meaning.
Likewise, the Government introduced a text exchange from Ms. Hockridge, purportedly
sent to Blueacorn customer Jessica Stackpoole on December 30, 2020, when Ms. Stackpoole
sought information about loan processing. 6/12 Tr. 9:11–9:16, 10:19–11:2. Ms. Hockridge stated
that she was in Dallas and would be returning to Arizona on December 31, 2020. Id. at (11:6–
11:8). This introductory text message is not evidence of an act in furtherance of a conspiracy.
Again, since the uncontroverted evidence shows that Blueacorn engaged in legitimate business
practices. There is no reason to think that, on December 30, 2020, Ms. Hockridge’s introduction
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of Ms. Stackpoole in an email from Mr. Reis included any attempt, intent, or other overt act to
further a fraud rather than a legitimate business act. Indeed, the Government did not introduce
evidence that any application submitted by Ms. Stackpoole was false or fraudulent in any respect.
And the mere fact that a business may engage in some criminal activity does not make every action
performed by that business “in furtherance” of that criminal activity. Cf. United States v. Miles,
360 F.3d 472, 478–79 (5th Cir. 2004) (noting that even a “substantial level of fraud” does not
necessarily transform a “legitimate business” into a purely fraudulent endeavor). Rather, it must
be shown that the act in question specifically advanced the purposes of the conspiracy. Cf. United
States v. Cornet, 195 F.3d 776, 783 (5th Cir. 1999) (holding a statement is not “in furtherance of
the conspiracy” under Rule 801(d)(2)(e) “unless the statement advances the ultimate objects of the
conspiracy”).
In the parties’ proposed charge, the Government argued that venue could be established by
the overt act of “an innocent agent who is acting at a conspirator’s direction.” Proposed Charge
(Doc. #143) at 66 n.41 (quoting United States v. Perez, 223 F. App’x 336, 340–41 (5th Cir. 2007)).
But Perez, an unpublished decision, relied only on a treatise that itself quoted out-of-circuit
authority. See Perez, 223 F. App’x at 341 & n.4 (quoting LaFave, Israel & King, Criminal
Procedure § 16.3(f) (2d ed. 1999)), and it is inconsistent with the Fifth Circuit’s definitive
construction of the law of conspiracy in United States v. Wieschenberg, 604 F.2d 326, 331 (5th
Cir. 1979) (stating that “[f]or a conviction of conspiracy, there must be proof of . . . an overt act
committed by one of the coconspirators in furtherance of the conspiracy” (emphasis added)).
Yet even if Perez were controlling, other acts that the Government relies on to prove
venue—transfers made by Happy State Bank—are not acts of any alleged coconspirators’
“agents”; to the contrary, Happy State Bank is merely a depository branch for Capital Plus
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Financial, the alleged victim financial institution, which was at arms-length from the borrowers,
and yet further removed from Ms. Hockridge herself. See 6/12 Tr. 293:12–293:18. Because venue
is only proper in a district in which a crime is committed, and because the crime of conspiracy is
committed only if a coconspirator performs an overt act in furtherance of the conspiracy, venue
over the conspiracy charge is not proper in this District. Thus, a judgment of acquittal must be
entered for the Government’s failure to establish venue for Count I.
B. The Government Has Likewise Failed to Demonstrate Venue for Any of the Wire
Fraud Counts
Ms. Hockridge also challenges the venue over the wire fraud charges in light of the
Government’s failure to establish that she was within the Northern of District of Texas when she
“caused” the transmission of the bank transfers described in Counts Two through Five. The Sixth
Amendment guarantees that a defendant will be tried in the district in which “district wherein the
crime shall have been committed.” U.S. Const. amend. VI. Federal Rule of Criminal Procedure18
similarly provides that “the government must prosecute an offense in a district where the offense
was committed.” But in this case Government has introduced no evidence to suggest that Ms.
Hockridge began, continued, or completed any of the offenses charged in Counts Two through
Five in this district.
Instead, the Government appears to base its claim of venue on the allegation that a bank
within this district, which is not alleged to have been a knowing participant in any scheme, sent a
wire transmission. That is simply insufficient. See Strain, 396 F.3d at 694 (explaining that
“circumstance elements” of an offense, such as knowledge or acts by a third party that “do not
involve any proscribed conduct by the accused” cannot “serve as a basis for establishing venue”).
The Government’s argument appears to echo the theory rejected by the Supreme Court in Loughrin
v. United States, 573 U.S. 351 (2014), in which the Supreme Court held that the mere fact that a
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bank disbursed funds as a result of a fraudulent statement to a third party was insufficient to create
federal jurisdiction for bank fraud. As the Supreme Court has long held, the bank, wire, and mail
fraud statutes should be construed together. See Neder, 527 U.S. at 20. Indeed, especially given
the complexity of the U.S. banking system, it would render the constitutional demand of the Sixth
Amendment toothless to allow venue to be based on nothing more than the fortuity that a wire
transfer happens to pass through a bank on its way from payor to payee, as the Government seeks
to do here. See Loughrin, 573 U.S. at 362 (holding that bank fraud statute does not “cover every
pedestrian swindle happening to involve payment by check, but in no other way affecting financial
institutions.”).
The Fifth Circuit denounced the venue theory the Government’s advances here over 60
years ago. In United States v. Boruff, the defendants, while located in the Northern District of
Georgia, fraudulently caused their victim to send money via wire from Michigan to Atlanta, in the
Northern District of Georgia. 310 F.2d 918, 922 (5th Cir. 1962). The next day, the defendants sent
the money via a second wire from Atlanta to a town in the Middle District of Georgia, where they
were tried and convicted for wire fraud. Id. The Fifth Circuit vacated their convictions, holding
that venue was improper: all of the Defendants’ acts causing an “interstate transmission” were
done and completed in Atlanta. The subsequent transfer could not render venue proper in the
Middle District of Georgia because 18 U.S.C. § 1343 requires “an interstate transmission,” not an
intrastate transmission within the State of Georgia. Id. at 922–23 (emphasis added).
So too here, the Government’s evidence ties the alleged wire fraud in Counts Two through
Five solely to the District of Arizona, where Ms. Hockridge resided on each of the dates reflected
in those counts. The Government has not introduced a shred of evidence that Ms. Hockridge began,
continued, or completed the charged act of causing a fraudulent wire transfer while she was in the
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Northern District of Texas, so it has failed to establish that venue was proper here. Even if Ms.
Hockridge traveled to this district at some point between 2020 and 2021, that would not make
venue proper here—any more than the Boruff defendant’s second wire transfer would subject him
to prosecution in the Middle District of Georgia.
In short, the Government had ample opportunity at trial to prove the Northern District of
Texas was a proper venue for this prosecution. It simply failed to do so. Thus, Ms. Hockridge is
entitled to judgment of acquittal on each count of the Superseding Indictment.
CONCLUSION
The Government has failed to prove a unified conspiracy or scheme to defraud. Likewise,
the Government has failed to prove that Ms. Hockridge intentionally joined any conspiracy or
knew about any materially false loan applications. And it has utterly failed to demonstrate that Ms.
Hockridge committed any act in this district either in furtherance of the conspiracy or as one of
the charged executions of the alleged scheme in Counts Two through Five. While the Government
may have presented “some evidence” to suggest that Ms. Hockridge worked with others who have
admitted to conspiring together to commit wire fraud, the Government has not presented sufficient
evidence to persuade a rational jury beyond a reasonable doubt that she was a knowing participant
in their fraudulent activities. For these reasons, Ms. Hockridge respectfully requests that the Court
enter a judgment of acquittal on all counts.
Dated: June 19, 2025 Respectfully submitted,
BRYAN CAVE LEIGHTON PAISNER LLP
/s/ Richard E. Finneran
RICHARD E. FINNERAN
211 North Broadway, Suite 3600
St. Louis, Missouri 63102
Tel: (314) 259-2000
Fax: (314) 259-2020
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richard.finneran@bryancave.com
Attorneys for Defendant Stephanie Hockridge
GALLIAN FIRM
/s/ Gregg Gallian
Gregg Gallian, TX Bar: 24085952
3500 Maple Avenue, Suite 1150
Dallas, Texas 75219
Tel: (214) 432-8860
Fax: (972) 433-5835
gregg@gallianfirm.com
Attorneys for Defendant Stephanie Hockridge
CERTIFICATE OF SERVICE
I hereby certify that on June 19, 2025, a true and correct copy of the foregoing document
was served on all counsel of record by operation of the Court’s CM/ECF system.
/s/ Richard E. Finneran
RICHARD E. FINNERAN
35
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